1 Minimum Allowed Size of Small Satellites
1.
We suspect that many of the commenters will not understand why NORAD can
catalog astonishingly tiny debris, including what may be a wire-tie dropped
by a spacewalking astronaut (1998-67NS [43498]), while FCC must insist on
a much larger minimum size for small satellites. However, there is an
excellent reason.
2.
For the security of North America, it is essential that foreign powers
remain unaware of fine details of the capability of NORAD, the United
States, and Canada to track small or *unreflective* objects in orbit.
“Stealth”, technology for reducing radar reflections, allows larger objects
to given the radar-reflective profiles of un-stealthed smaller ones. The
minimum radar-reflective profile capable of being tracked by NORAD should
remain unknown. Thus, no object should be licensed for launch if its
radar-reflective profile in any orientation is close – within a classified
amount - to the minimum tracking capability of NORAD, the U.S., or Canada.
We suspect that the 100mm2 standard minimum cubesat size far exceeds
this minimum capability, perhaps by an order of magnitude. As technical
capabilities improve, the minimum licensable size should be reduced,
however the size allowed must always be some classified amount larger than
the actual minimum radar profile that can be reliably tracked.
3.
That said, ORI is interested in launching constellations of many very
small satellites into LEO, where their orbits would decay to re-entry
within a few years and they could not be expected to be a long-term
collision hazard. We urge FCC to allow licensing of such things as soon
as this is possible within the constraints of national and North American
security.
--
Bruce Perens K6BP - CEO, Legal Engineering
Standards committee chair, license review committee member, co-founder,
Open Source Initiative
President, Open Research Institute; Board Member, Fashion Freedom
Initiative.
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